Toggle menu

Disproportionate burden assessment for PDF documents

Due to the vast number of documents on the website, to amend every document would be a disproportionate burden so we are unable to rectify this problem completely. We are working to replace or improve the accessibility of commonly used documents where possible.

We are fully committed to making all active documentation fully accessible. Ideally this would mean creating them as HTML web pages, or where PDF documents are required, making sure these documents meet accessibility guidelines.

We are prioritising reviewing and replacing documents which get the highest use on our site.


The benefits of reviewing and making PDFs documents accessible, or changing the format into HTML pages would be:

  • All materials would be fully accessible to all users
  • Content would be more easily searchable and indexable

Impact on users

It is worth noting that most of our content and services are accessible without the need to use PDF documents published on the site. Some PDF documents only provide an alternative format to information published as HTML content.

From 13 October 2020-13 October 2021, approximately 1% of website sessions included a PDF download (according to data provided by Google Analytics).

As such, any inaccessible PDFs currently published on the website, impact a very small proportion of our website users.


There are currently 8,055 PDF documents published on

According to Google Analytics data, 6,282 of these PDFs have been viewed in the past year (October 2020 to October 2021), which equates to 79% of the PDFs we have available on the site.

Any PDFs which have not been viewed in the past year can be considered 'inactive'. We will not review or remove these inactive PDF documents as they are not negatively impacting users since these documents are not being used. For this reason, we don't believe the cost of time, effort and resource to fix inactive documents is justified.

We instead will focus our time to replace PDF documents which we know are being used by our website users, or where they are required for essential services.

Of the 6,336 PDF documents which can be considered 'active' - around 7 per cent, (approximately 458) of these have been viewed by 50 or more people in the past year.

We are reviewing the documents in order of the volume of views according to Google Analytics data. We aim to review this top 7 per cent of documents as a starting point. We will amend and re-upload documents as accessible versions or replace content with HTML pages.

Resolution time scales

It is difficult to know without reviewing each document first how long this task would take. Based on an assumption that each PDF would take a minimum of 1 hour to review and replace, this is at least 63 days of work (based on an average 7 hour and 24-minute working day), but likely more.

As this is such a large amount of work, we will aim to complete the review of the most used documents by the end of 2022.

As the length of time each piece of work is difficult to predict, we may need to adjust this timeframe in future based on progress being made. For example, if many of the top 7 per cent of documents are taking longer than 1 hour to review and replace, we may need to extend this timeframe.

When we have completed this initial work, we will reassess PDF usage across the website and provide our approach to any work left to complete.

Relevant information

We will respond to requests for documents in different formats as quickly as possible. So accessible versions are available on demand, with a short lead-time. We hope this will alleviate any significant issues PDF content may be causing any of our users.